Section 104(b) of the Consumer Product Safety Improvement Act (CPSIA of 2008) requires the Consumer Product Safety Commission (CPSC) to set in place a final ruling regarding product registration cards for durable infant and toddler goods by August 14, 2009. However, the notice of proposed rule making (NPR) published in the federal register today indicates that public comments are not due until September 14, 2009. Furthermore, the notice proposes that the effective date for registration cards will be 180 days after the final rule is published, rather than the customary 30 to 90 days.
Assuming the final rule is published 30 days after all comments are received, registration cards may not be required until mid-April 2010.
For manufacturers and importers who had anticipated having to include cards and develop database tracking systems by fall 2009, this news will come as a welcome, if only temporary, reprieve. To consumer advocates who had been promised the hope of a more effective product recall system, the news is undoubtedly disappointing.
Whether you agree or disagree with the proposals, now is the time to speak up. The Commission is seeking comments on everything from whether a definitive list of “durable goods” ought to be made available to whether or not the prepaid return cards should follow a mandatory format. Above is an image of the proposed cards that the Commission is currently suggesting every manufacturer adopt (click the image to enlarge).
The proposed layout is a perforated card whereby the top half can be kept by the consumers for their records and the bottom half returned to the manufacturer. The CPSIA mandates that the cards include the model name and number and the manufacture date, which the Commission proposes can be be pre-printed or affixed with a label.
One of the questions raised is whether the proposed design is likely to improve safety. For example, are consumers likely to keep the stub they tear off and, should they have a safety question several years later, are they likely to refer to the card rather than look up the manufacturer online or in a directory? If the answer is no, then perhaps the double-sized, perforated card is unnecessary. Another question the Commission asks is whether or not manufacturers should be allowed to offer registration by email rather than maintaining a webpage where consumers can register their products.
You can submit your comments to the CPSC via the regulations.gov website, here. Please note that your name, contact information and comments, as submitted, will be printed for public view.
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